The supply chain of service providers delivering services to TSB (i.e. the entities to which SABIS had subcontracted certain tasks), Mr Abarca retained responsibility within TSB for the migration. While the testing of the readiness of the new IT platform was the responsibility of SABIS (Sabadell’s IT subsidiary, which provided core IT services on an intra-group outsourced basis following the migration) in conjunction with fourth party providers (i.e. All 550 of TBS’s branches and a significant proportion of its customers were materially impacted. The Incident resulted in a significant disruption to the continuity of TSB’s provision of core banking immediately post migration, with some more limited issues persisting for a sustained period of months. Immediately following the migration, TSB encountered serious issues, including failures with online, telephone and mobile banking services, branch technology failures, and consequential issues with payment and debit card transactions (the Incident). In 2018, following a process that lasted a number of years, TSB proceeded to migrate its IT services from LGB to Sabadell. Mr Abarca, as TSB’s CIO, held an SMF18 position (Other Overall Responsibility) throughout the relevant period and was responsible for TSB’s information technology and IT business continuity planning. ( Sabadell) acquired TSB via a takeover, with Mr Abarca moving from Sabadell to become TSB’s CIO shortly after this acquisition. Following the divestment, LBG continued to provide a number of services to TSB, including providing access to LBG’s IT platform for a period of up to 10 years. TSB was formed as a result of a Lloyds Banking Group ( LBG) divestment in June 2014. TSB is regulated by the PRA for prudential purposes and by the Financial Conduct Authority ( FCA) for conduct matters. 1 The relevant period covered by the Final Notice is from 7 March 2016 to 22 April 2018. On 13 April, the Prudential Regulation Authority ( PRA) issued a Final Notice against Carlos Abarca (TSB’s Chief Information Officer ( CIO)), imposing a fine of £116,000 (reduced to £81,620 upon settlement) for failure to comply with Senior Manager Conduct Rule 2.
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